PRIVACY POLICY

INTRODUCTION

Adtoox AB, reg.no 556727-3569 (“Adtoox,” “we,” “us” or “our”) will process your personal data when you register a user account at adtoox.com and when you are using the services provided under your user account. We strive to be transparent in what we do with your personal data and have therefore adopted this privacy policy. Below, you will find information on what kind of personal data we process, why we do it, what we use it for and how we may share it. Adtoox is the data controller of any processing of your personal data.

IF YOU HAVE NOT LOGGED IN AND ARE BROWSING ADTOOX’ HOMEPAGE

Adtoox, with exception for the use of cookies (see Adtoox’ Cookie Policy), does not collect personally identifiable data from your visit to its domains, including but not limited to www.adtoox.com, other than information that you voluntarily supply. By using any publicly available contact channel, you agree that your contact details are correct and rightfully yours. They will be used solely by Adtoox to respond to your query.

IF YOU HAVE A USER ACCOUNT

Adtoox will process your personal data when you register a user account at adtoox.com and when you are using the services provided under your user account.

For the avoidance of doubt, Adtoox is not considered to be data controller for content that you may upload into the Adtoox services. In this respect, Adtoox is considered to be data processor.

If you have questions on Adtoox’ processing of your personal data, you can contact us at privacy@adtoox.com.

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What personal data does Adtoox process?
When you register a user account, Adtoox will collect certain personal data from you in order to make the services available to you. Such personal data will include your email, first name, surname, title and phone number. Further, when you have created a user account, we will collect data related to your activities under your account (jointly “User Data”).

How Adtoox uses your User Data and Adtoox’ legal basis.
We will process your User Data for the purposes of providing the Adtoox Services (including, but not limited to, Express, Play and Research) to you. The legal basis for such processing is that it is necessary for the performance of our service agreement(s) with you. However, if you are an employee or other representative of a company which has entered into a service agreement with us, the legal basis for such processing is that it is necessary for our legitimate interest to provide the services to the company (including its employees and representatives) in accordance with the services agreement.
If you request support through our support channels (e.g. email and telephone), we will process User Data to be able to assist you with the relevant matter. The legal basis for such processing is that it is necessary for our legitimate interest of maintaining good customer relations.
Further, we will not process User Data for the purpose of direct marketing unless you have agreed to receive such direct marketing (meaning that Adtoox may send you information and offers about similar products or services which Adtoox believes may be of interest to you). The legal basis for our processing is that it is necessary for our legitimate interest of maintaining good customer relations. You may always object to direct marketing from us, see further information under “Your rights” below.

How long we will keep User Data.
If you have entered into a service agreement with us, we will process your User Data during the term of our agreement and for a period of 3 months thereafter. After such period, we will anonymize your User Data.
If you are an employee or other representative of a company which has entered into a service agreement with us, we will process your User Data during the term of the service agreement between us and the company and for a period of 3 months thereafter. After such period, we will anonymize your User Data.
If you do not use or log on to your user account for more than 12 months, we will contact you to ask whether you wish to erase your user account (i.e. User Data).
Notwithstanding the above, we may need to keep certain User Data for a longer period to comply with applicable law (including book-keeping requirements). If so, we will not use your User Data for any other purposes.

WHO DOES ADTOOX SHARE USER DATA WITH?

Only the people who need to process User Data for the purposes mentioned above have access to your User Data. We may need to allow our suppliers access to your User Data when they perform services on our behalf, mainly to provide support and maintenance of IT systems, storage services and marketing.

TRANSFERS OF USER DATA OUTSIDE THE EEA

Adtoox will not transfer your User Data to a country outside the European Economic Area (EEA).

YOUR RIGHTS

You are entitled to the following rights under applicable laws:

The right to access: you may at any time request to access your User Data. Upon request, Adtoox will provide a copy of your User Data in a commonly used electronic form.

The right to rectification: you are entitled to obtain rectification of inaccurate User Data and to have incomplete personal data completed.

The right to erasure (“right to be forgotten”): under certain circumstances, you may request us to delete your User Data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an immediate action from Adtoox.

The right to object: you are entitled to object to certain processing activities conducted by us in relation to your User Data, such as our processing of User Data based on our legitimate interest. The right to object also applies to processing of your User Data for direct marketing purposes.

The right to restriction of processing: you may under certain circumstances request from Adtoox to restrict the processing of your User Data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.

The right to data portability: you are entitled to receive User Data (or have User Data directly transmitted to another data controller) in a structured, commonly used and machine-readable format.

If you have any questions about how we process your User Data, or if you want to exercise your rights in accordance with the above, please feel free to contact us at privacy@adtoox.com. In case of any issues in relation to your User Data or other privacy concerns, you may also lodge a complaint with the Swedish data protection supervisory authority (Swe: Datainspektionen).